It stays awaiting exit01
With release but no exit, the declaration stays at PS and the invoice has no proof of the exemption. Before treating the export as done, check the status with the MRN (CCAESC).
Export:
the DUA in the AES
The export DUA (Single Administrative Document) is the declaration that the exporter or its representative lodges in the AES, the export system of the Spanish Tax Agency (AEAT), before the goods leave the Union. The AEAT returns an MRN, grants release and records the actual exit, which proves the VAT exemption of article 21 of the Spanish VAT Act (Ley del IVA, LIVA).
AES is the Automated Export System (Sistema Automatizado de Exportación); MRN, the Movement Reference Number. Release (levante) authorises the goods to leave; actual exit (salida efectiva) confirms that they left. Only the second one counts to support the exemption.
Who lodges
the export
declaration?
The exporter lodges it or, on its behalf, a customs representative under direct or indirect representation, signing with an electronic certificate. The declarant and the representative are identified by their EORI number (Economic Operators Registration and Identification), which is not the same as the Spanish tax ID (NIF).
The message is CC515C, from the AES web services guide. It is used to export outside the Union (type EX) and to send goods from mainland Spain to the Canary Islands (type CO). It declares where the goods are: a customs area or premises authorised for export (local autorizado para la exportación, LAME).
When the office of exit is not the office of export (indirect exit, for example through another port or another Member State), the arrival of the goods at the office of exit is notified with CC507C.
What do you need to file
the export declaration?
You need the exporter's EORI number and an electronic certificate or electronic ID card. The declaration is sent with a program connected to the AES web services, with the export form on the AEAT's e-office or through a customs representative.
| How | What it involves | Who it suits |
|---|---|---|
| Customs software connected to the AEAT | Builds the declaration (CC515C) and sends it to the AES web services with an electronic certificate. | Customs representatives, freight forwarders and frequent exporters. |
| The e-office export form | The AEAT's e-office has an export form (“Alta DUA - Formulario de exportación - Sistema AES”) to file it by hand, with an electronic certificate or ID card, on your own behalf or proving the representation. | One-off exports. |
| A customs representative | Files the declaration for the exporter, under direct or indirect representation. | Anyone who would rather not file it themselves. |
General information; not customs advice.
What types of export
declaration are there?
The additional declaration type says whether it is a full declaration, a simplified one or a pre-lodged one. If none is chosen, it is type A. These are the definitions in the AEAT's AES web services guide v1.25.
| Type | What it is | What follows |
|---|---|---|
| A | Standard declaration, with all the data | Release and, later, actual exit |
| B | Simplified declaration for missing documents | One, and only one, supplementary declaration X (CC515X) with the same MRN |
| C | Simplified declaration for regular use (art. 166.2 UCC), with authorisation C512 | Summarised later in a type Y declaration |
| D | Pre-lodged type A | Presentation of the goods (CC511C), then it becomes A |
| E | Pre-lodged type B | CC511C, it becomes B, then the supplementary X |
| F | Pre-lodged type C | CC511C, then it becomes C |
| Y | Summary declaration for type C | Another CC515C with its own MRN; each item cites the MRN of the C it summarises (document 1220) |
| Z | Supplementary declaration under art. 182 UCC (entry in the declarant's records) | Full CC515C with authorisation C514 |
General information; not customs advice. Simplified types C, F, Y and Z require the authorisation shown.
Step by step How is an export processed in the AES?
How is an export processed in the AES?
From the declaration to actual exit.
Declare or pre-lodge
You send CC515C. If the AEAT accepts it, it returns the MRN and the acceptance date. A pre-lodged declaration (D, E or F) stays at status PA, and the goods must be presented (CC511C) within 30 days.
Control channel and release
The AEAT assigns a control channel (circuito). On green, automatic release arrives with its CSV (secure verification code); on orange or red, the declaration stays under control until customs decides.
Arrival at the office of exit
With indirect exit, the goods travel to the office of exit and their arrival is notified with CC507C. If the AEAT consults a foreign customs office, the notice is repeated after 15 minutes.
Actual exit
The office of exit confirms that the goods have left the Union and the declaration moves to SA. It arrives through the AES inbox (ComunicaResulSalida) or the CCAESC query. Release does not replace it.
Receipts by CSV
Each response carries its CSV: declaration, release, T2L/T2LF and certificate of actual exit (CCCSEC). With the CSV, the document can be checked and downloaded on the AEAT e-office (Sede).
Scroll
The export number What is the
What is the
export MRN?
The MRN (Movement Reference Number) is the 18-character number the AEAT assigns when it accepts the declaration. It identifies the export across the Union: it is cited by the transit that continues from it, by the exit summary declaration (EXS) and by the EAD (DAE in Spanish), the export accompanying document. The LRN, by contrast, is the declarant's own reference, up to 22 characters long.
The MRN in transit (NCTS)What does each export status
mean in the AES?
The AEAT publishes the statuses in its EXESTAES table. Two matter for the exemption: PS (awaiting exit) does not prove anything yet; SA (actual exit) does.
| Code | Status |
|---|---|
| PA | Pre-lodged |
| PL | Awaiting release |
| DE | Released (indirect exit) |
| DS | Released (direct exit) |
| PS | Awaiting exit |
| RE | Received and awaiting release at the office of exit |
| RQ | Requested from the country of dispatch |
| AW | Awaiting the control decision of the foreign office of presentation |
| ET | Awaiting transit |
| GT | Handled by transit |
| SA | Actual exit: the proof that the goods left |
| ST | Stopped for discrepancies at exit |
| IV | Invalidated |
VAT
How do you prove that an export is exempt from VAT?
Article 21 of Ley 37/1992, the Spanish VAT Act, exempts supplies of goods that leave the Union. The invoice shows exemption reason E2 (“exempt under art. 21”), and the proof is the actual exit recorded by the AEAT with the MRN of that export.
- 01 Invoice E2 Issued without VAT, with the article 21 exemption reason and a reference to the export.
- 02 MRN The one of the declaration that covers that supply: it links the invoice to the exit.
- 03 Exit SA Actual exit status in the AES. Release only authorises the exit; it does not prove that it happened.
- 04 Receipt The certificate of actual exit (CCCSEC) or the receipt downloaded from the e-office with its CSV.
- Never Invalidated An invalidated declaration does not prove exit, even if it had been released.
What happens if the goods never leave?
Discrepancies at exit02
The office of exit stops the declaration (status ST) when what arrives does not match what was declared: weights, packages, containers or seals. Until this is resolved, no exit is recorded.
Request invalidation03
If the operation will not go ahead, you request it with CC514C and a reason. Requesting it is not the same as invalidating: the declaration is only cancelled when the AEAT replies with status IV.
Declare again04
After release, the general way to correct is to invalidate and lodge a new declaration with document 1224 and the invalidated MRN (AES guide v1.25, §8.4 and §12).
Expired pre-lodged declaration05
If a pre-lodged declaration is not presented within 30 days, the AEAT invalidates it on its own initiative and reports it through the AES inbox (ComunicaInvalidacion).
No exit, no proof06
Until actual exit is recorded, the invoice has no article 21 proof. If the goods are not going to leave, review the VAT treatment of the supply with your tax adviser.
What are the deadlines and how
long is the proof kept?
The AES guide sets the procedural deadlines. How long to keep the proof depends on the Spanish General Tax Act (Ley General Tributaria): the exemption can be audited until the AEAT's right to review the VAT expires.
| What | Deadline | Source |
|---|---|---|
| Pre-lodged (D, E, F) | Present the goods within 30 days of acceptance; otherwise the AEAT invalidates the declaration on its own initiative | AES guide v1.25, §4.3.3 and §5.4 |
| Supplementary X (type B) | 30 days from release as the general limit, unless the customs office sets another | Delegated Regulation (EU) 2015/2446 |
| Arrival (CC507C) | Repeat the notice after 15 minutes if the AEAT is consulting a foreign customs office | AES guide v1.25, §6 |
| Exemption proof | As long as the AEAT can audit the VAT on that supply: a four-year limitation period, which interruptions can extend | Ley 58/2003 General Tributaria, arts. 66 to 70 |
General information; not tax or customs advice. The deadline of a specific authorisation is set by the customs office.
Questions about exports and the AES
The most common questions about the export DUA, the MRN and the VAT exemption.
What is the export DUA?
It is the customs declaration used to export goods outside the European Union. DUA stands for Documento Único Administrativo, the Spanish name for the Single Administrative Document. In Spain it is lodged in the AES, the Automated Export System of the Spanish Tax Agency (AEAT), with message CC515C. If the AEAT accepts it, it returns an MRN that identifies the export until exit.
Who lodges the export declaration?
The exporter, or a customs representative on its behalf under direct or indirect representation, signing with an electronic certificate. The declarant and the representative are identified by their EORI number, which is not the same as the Spanish tax ID (NIF).
What is the difference between release and actual exit?
Release (levante) authorises the goods to leave; actual exit (salida efectiva, status SA) confirms that they have left the Union. Only actual exit proves the export: a released declaration can stay at awaiting exit (PS) or be invalidated.
What is the MRN and where do I find it?
The MRN (Movement Reference Number) is the 18-character number the AEAT assigns when it accepts the declaration. It comes in the acceptance response and on the declaration's receipts. You use it to check the status of the export in the AES.
How do I prove that an export is exempt from VAT?
The invoice is issued without VAT, with the exemption reason of article 21 of Ley 37/1992 (E2 in VeriFactu). As proof, you keep the actual exit recorded by the AEAT for the MRN of that export: the certificate of actual exit or the receipt downloaded with its CSV. Release is not enough.
What happens if the goods do not leave after release?
The declaration stays at awaiting exit and the invoice has no proof of the exemption. If the operation will not go ahead, you request invalidation with CC514C. Requesting it is not the same as invalidating: the declaration is only cancelled when the AEAT replies with status IV.
Can an export declaration be corrected after it is lodged?
Amendment (CC513C) is for pre-lodged declarations and for very limited cases after acceptance. After release, the general route is to invalidate the declaration and lodge a new one with document 1224 and the invalidated MRN (AES guide v1.25, §8.4 and §12).
How long must the export proof be kept?
As long as the AEAT can audit the VAT on that supply: the limitation period is four years (art. 66 of the Ley General Tributaria, the Spanish General Tax Act) and interruptions can extend it. The receipt with its CSV can be checked again on the AEAT e-office (Sede electrónica).
What software do you need to file an export declaration?
If you export often, a program that builds the declaration (CC515C) and sends it to the AES web services with an electronic certificate. For a one-off export, the AEAT has an export form on its e-office, used with an electronic certificate or ID card. Both need the exporter's EORI number.
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